Gypsy and Traveller Accommodation Topic Paper Joint Chiltern and South Bucks Local Plan 2036 - April 2019

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Gypsy and Traveller Accommodation Topic Paper Joint Chiltern and South Bucks Local Plan 2036 - April 2019
Classification: OFFICIAL

Gypsy and Traveller Accommodation
Topic Paper
Joint Chiltern and South Bucks Local
Plan 2036

April 2019

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Gypsy and Traveller Accommodation Topic Paper Joint Chiltern and South Bucks Local Plan 2036 - April 2019
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Contents
Executive Summary .............................................................................................................................. 3
Introduction ........................................................................................................................................... 5
The national context............................................................................................................................. 5
The Buckinghamshire context ............................................................................................................. 6

The overall need for new Gypsy and Traveller pitches in Chiltern and South Bucks................... 6
Transit sites ............................................................................................................................................ 8

Cultural needs for gypsy and traveller pitches ................................................................................. 8
Chiltern and South Bucks Local Plan consultation documents relevant to the provision of
Gypsy and Traveller accommodation ................................................................................................ 9
Methodology....................................................................................................................................... 12

Overview .............................................................................................................................................. 12
Initial assessment ................................................................................................................................ 12
Testing of constraints ......................................................................................................................... 19
Intensification opportunities from existing traveller sites within the Green Belt ....................... 22
The Chalfont St Peter Neighbourhood Plan ................................................................................... 23
Pitch provision as part of site allocations in the new Local Plan .................................................. 24

Findings ................................................................................................................................................ 26
Conclusions ......................................................................................................................................... 28

References ........................................................................................................................................... 30
Appendix 1 – Overview map of existing sites in the plan area referred to in the GTAA........... 32
Appendix 2 - Site Assessment Methodology notes on proximity indicators ............................. 33

Appendix 3 - Existing gypsy and traveller sites - analysis of constraints .................................... 35
Appendix 4 – List of existing sites and relevant planning applications ....................................... 36

Appendix 5 - Site proformas for selected gypsy and traveller sites ............................................ 40
Appendix 6 - Mechanisms / conditions which can be used to control the impacts of new
pitches .................................................................................................................................................. 63

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Executive Summary

     1. This paper sets out the Councils’ work to address the needs of the Gypsy and
         Traveller community for new pitches during the period of the Local Plan (2016 –
         2036). There are at least 137 gypsy and traveller households living within the Local
         Plan area. This paper includes the results of assessing the future accommodation
         needs of this community as identified within the Gypsy Traveller and Travelling
         Showpeople Accommodation Assessment (GTAA) (2017). The GTAA was carried out
         by independent consultants, Opinion Research Services (ORS) for all of the District
         Councils within Buckinghamshire. The different types of need arising from the GTAA
         falls within two categories for Chiltern and South Bucks Districts – unknown needs
         and the needs of those not-travelling at the time of the assessment. No transit sites
         for gypsies and travellers were found to be needed.

Table 1 Overall pitch needs for Gypsies and Travellers in Chiltern and South Bucks (2016 –
2036) (all types, based on the GTAA)

 Type of need         Immediate Longer        Longer      Longer
                                term          term        term
 Years                0-5         6-10        11-15       16-20
                      2016-21     2021-26     2026-31     2031-36    Total
 Chiltern         8               2           2           3          15
 Gypsies      and
 Travellers (non-
 travelling)
 South       Bucks 16             5           6           6          33
 Gypsies      and
 Travellers (non-
 travelling)
 South   Bucks 21                 5           5           6          37
 (unknown)
 Joint Plan area 45               12          13          15         85
 in total

     2. Given this context, and in consideration of national planning policy advice, good
         practice and relevant local – level policies and the Sustainability Appraisal,       the
         Councils needed to consider how best to address these types of need and their
         approach was to aim to address all needs based on the cultural needs of the local
         traveller community. This approach has also been used in other parts of the country
         and is an appropriate course of action for the particular circumstances of Chiltern
         and South Bucks. Indeed it is noted that the some of the gypsy and travellers
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         households living in the Local Plan area may decide to resume their travelling habits
         in the future and so could potentially comply with the requirements in national
         planning policy, Planning Policy for Traveller Sites (2015) for the definition of
         travelling.

     3. Opportunities to meet this accommodation need were then taken forward as part of
         an assessment described in the methodology section of this paper. The role of
         existing sites already occupied by gypsies and travellers is highlighted as a suitable
         option to help address needs, close to where they arise as is the role of four site
         allocations in the new Local Plan (at Chesham, Little Chalfont, north of Iver Station
         and Beaconsfield)

     4. The findings of the site assessment process described in this Topic Paper show that
         of the 85 pitches needed overall there is a potential supply of 81-87 pitches. Of
         these, 35-40 pitches can be expected to be delivered within the first five years
         against the overall five year pitch need of 45. It is noted in the findings section of
         this Topic Paper that one of the existing sites in Iver has now been the subject of a
         permanent permission for one pitch. Therefore this effectively reduces the
         outstanding number of pitches to meet all needs by one to 84 pitches (and to 44 for
         the first five years).

     5. For the avoidance of doubt it is stated here that this paper does not cover the needs
         of Travelling Showpeople. These needs are addressed separately in the Local Plan.

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Introduction

     6. The purpose of this Topic Paper is to summarise the evidence of the needs of
         accommodation for gypsies and travellers over the Local Plan period to 2036 and to
         describe how it is proposed that those needs will be met. The needs have been
         identified in the Aylesbury Vale, Chiltern, South Bucks and Wycombe District
         Councils’ Gypsy Traveller and Travelling Showpeople Accommodation Assessment
         (Feb 2017) (This Assessment is hereafter referred to as the ‘GTAA ‘in this paper).

     7. There are gypsy and traveller communities living in Chiltern and South Bucks.
         According to the GTAA there were 26 Gypsy and Traveller households living in
         Chiltern District and 111 Gypsy and Traveller households living in South Bucks
         District. 137 households in total at that time.

     8. A map of the Gypsy and Traveller Sites within the Plan Area which were recorded in
         the GTAA is included as Appendix 1 to this paper.

The national context

     9. This topic paper is guided by three national – level planning documents. These are
         the 2019 National Planning Policy Framework (NPPF), the National Planning Policy
         Guidance (NPPG) and Planning Policy for Traveller Sites (PPTS) (2015). The linkages
         between these documents is acknowledged in paragraph 4 of the NPPG which
         states, “The Framework should be read in conjunction with the Government’s planning
         policy for traveller sites, and its planning policy for waste. When preparing plans or
         making decisions on applications for these types of development, regard should also be
         had to the policies in this Framework, where relevant”.

     10. Other key references to Gypsies and Travellers in the NPPF are in relation to the
         scope of Local Plan policies concerning the needs for different types of
         accommodation (paragraph 61). There is also the advice on the position for five year
         supply matters – separating the assessment of supply for travellers out from that for
         other housing. According to NPPF para 73 footnote 36 , For the avoidance of doubt,
         a five year supply of deliverable sites for travellers – as defined in Annex 1 to Planning
         Policy for Traveller Sites – should be assessed separately, in line with the policy in that
         document.

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The Buckinghamshire context

     11. The GTAA also covered Aylesbury Vale and Wycombe District Council areas. For
         Aylesbury Vale the total number of existing gypsy and traveller households was 111.
         For Wycombe the total number of existing gypsy and traveller households was 55. If
         the total level of need from all types is considered the pitch figures for Aylesbury
         would be 100 and for Wycombe 15 for their Local Plan periods to 2033.

     12. The District authorities in Buckinghamshire have worked closely on the GTAA.
         Provision of gypsy and traveller accommodation is a key strategic matter referred to
         in the Bucks Memorandum of Understanding on Local Plan preparation1.

The overall need for new Gypsy and Traveller pitches in Chiltern and South
Bucks

     13. The overall number of new pitches needed from all sources is set out in Table 1
         below. This has been based on the information in the GTAA. As a headline figure and
         irrespective of whether respondents were found to be travelling at the time of the
         survey, a total of 85 pitches for the gypsy and traveller community were estimated to
         be needed to up 2036. This approach has been taken so that the cultural needs for
         new accommodation have been taken into account as well as the Councils’ duties
         under Equalities legislation.

1
 link to Bucks MOU - https://www.chiltern.gov.uk/media/10814/Buckinghamshire-Memorandum-of-
Understanding-AVDC-WDC-SBDC-CDC-and-Bucks-Thames-Valley-LEP-July-2017-
/pdf/Bucks_Districts___LEP_MOU_FINAL_18.7.17.pdf?m=636360535921500000

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Table 1 Overall pitch needs for Gypsies and Travellers in Chiltern and South Bucks (2016 –
2036) (all types, based on the GTAA)

 Type of need         Immediate Longer         Longer      Longer
                                term           term        term
 Years                0-5         6-10         11-15       16-20
                      2016-21     2021-26      2026-31     2031-36     Total
 Chiltern         8               2            2           3           15
 Gypsies      and
 Travellers (non-
 travelling)
 South       Bucks 16             5            6           6           33
 Gypsies      and
 Travellers (non-
 travelling)
 South   Bucks 21                 5            5           6           37
 (unknown)
 Joint Plan area 45               12           13          15          85
 in total

     14. The GTAA classifies its findings in terms of whether respondents were found to be
         travelling or not in accordance with the PPTS definition. This information has been
         included in the table above. For Chiltern and South Bucks the respondents were
         found either to be non-travelling or that their needs were not known (not surveyed
         and so recorded as unknowns). At the time of the GTAA survey no respondents were
         found to meet the definition of travelling in the PPTS. It is acknowledged that
         compliance with the PPTS could change, for example a Gypsy or Traveller family or
         head of household could resume a travelling lifestyle at any time dependent upon
         their own aspirations, cultural needs and circumstances.

     15. Therefore, the Councils needed to consider how best to address these types of need.
         This was subject to the overarching consideration of national planning policy advice,
         good practice and relevant local – level policies and the Sustainability Appraisals for
         the Local Plan. The resulting approach of the Councils is to aim to address all needs
         based on the cultural needs of the local traveller community. This approach has also
         been used in other parts of the country and is an appropriate course of action for
         the particular circumstances of Chiltern and South Bucks with 137 gypsy and traveller
         households already living in the two Districts at the time of the GTAA.

     16. The GTAA applies a household growth rate to the households found to be non-
         travelling or whose needs were unknown. This can be found in Appendix C Figs 48,

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         50, 54 and 56 of the GTAA. This provides a forecast of overall need for this
         community. It is acknowledged that some of the pitches included in the forecast
         could help meet needs for households who comply with the PTTS definition in
         future. This is an appropriate and reasonable course of action given that there is a
         level of uncertainty as to future travelling habits. This approach links in well with the
         Councils’ focus on meeting cultural needs.

     17. The base date for the GTAA was February 2016. There were no applications for new
         pitches permitted in February and March 2016. Therefore the start date for the GTAA
         can be reasonably linked to start of the new Local Plan period from 1.4.2016.

Transit sites

     18. The GTAA does not recommend that a transit site should be provided in
         Buckinghamshire but that the LPAs should adopt an approach of ‘negotiated
         stopping’ and that there was a need to monitor the situation (paragraphs 7.83 and
         7.84). Therefore the provision of a transit site is not recommended in the Local Plan
         or referred to in this Topic Paper. Unauthorised encampments are monitored by the
         Bucks CC Traveller Unit and unauthorised developments are dealt with under the
         Council’s Planning Enforcement role.

Cultural needs for gypsy and traveller pitches

     19. Romany Gypsies and Irish and Scottish Travellers are a recognised protected ethnic
         group under the 2010 Equalities Act and have a need for culturally-suitable
         accommodation. This links to the Councils’ public sector equality duties to eliminate
         racial discrimination and promote equality of opportunity and the requirements of
         the Human Rights Act 1998. Section 124 of the Housing and Planning Act 2016 is
         also relevant. This refers to the duty to consider the needs of those resorting to /
         residing in caravans. As a result there is a duty for the Councils to have regard to the
         specific needs of these groups in carrying out their functions as a local housing
         authority, which in turn links into the Councils’ role in preparing a new Local Plan
         and its supporting evidence base. Of key importance here is the overall assessment
         of accommodation needs in the joint plan area as well as the GTAA.

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     20. The Buckinghamshire Housing and Economic Development Needs Assessment2
         (HEDNA 2016) include advice about the needs of the travelling community
         (paragraphs 8.77 – 8.82). It notes that pitches provided for the travelling community
         in the Local Plan period can be counted towards meeting the Districts’ objectively
         assessed housing need. Also it states that households whose needs do not fit the
         definition of travelling within PPTS will form part of the need arising from people
         residing in caravans, giving a close link to the circumstances in the Joint Local Plan
         area which are reflected in the GTAA.

     21. As a result of this context the Councils will need to consider the overall need for new
         pitches shown in the GTAA, not just those that emerge from evidence of travelling.
         This means that the Local Plan policies relating to these communities will need to
         assist in the delivery of new pitches, irrespective of whether the occupants were
         found to be travelling at the time of the GTAA survey. The NPPF 2019 acknowledges
         that Councils should include policies for specific accommodation needs / for specific
         groups and gives flexibility for Councils to tailor their policies to local circumstances
         (paragraph 61).

     22. An approach to addressing the cultural need for accommodation has been taken by
         a number of local authorities in their local plans. Examples are the Guildford and
         Maidstone Local Plans, and the Central Lincolnshire Joint Core Strategy. Closer to
         Chiltern and South Bucks, the Aylesbury Vale Local Plan, which is currently at
         examination, included policies to cater for those whose needs were unknown at the
         time of the GTAA survey. This is also a practical approach given the fact that the
         travelling habits of the occupants of a site could change at any time. This matter was
         accepted by the Inspector and no additional questions were raised on meeting GTAA
         need as part of the Examination hearings held in 2018.

Chiltern and South Bucks Local Plan consultation documents relevant to the
provision of Gypsy and Traveller accommodation

     23. In January 2016 the Regulation 18 consultation on Issues and Options for the Joint
         Local Plan3 referred to the range of opportunities for meeting traveller
         accommodation needs. This included the options set out in the table below.

2
 http://www.chiltern.gov.uk/media/9080/Housing-and-Economic-Development-Needs-Assessment-
December-2016-/pdf/Bucks_HEDNA_Update_(December_2016).pdf?m=636637060077030000

3
  https://www.chiltern.gov.uk/media/7771/Chiltern-and-South-Bucks-Local-Plan-Regulation-18-
Incorporating-Issues-and-Options-Consultation-Document-Jan-Mar-2016-
/pdf/FINAL_Reg_18__Issues_and_Options_Consultation_Paper.pdf?m=635883791899170000
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6.1    Options for meeting the needs of travellers are considered to be:

       a) Protect existing lawful sites solely for use by travellers, travellers being defined by
          national policy;

       b) Infilling where appropriate within existing lawful traveller sites, subject to the sites
          being appropriate to be removed from the Green Belt;

       c) Proposed extension of The Orchards, Chalfont St Peter as supported in the
          emerging Chalfont St Peter Neighbourhood Plan;

       d) New pitches/plots to be required as part of residential extensions to built-up areas
          comprising 100 or more dwellings;

       e) Consideration of nominations under the Call for Sites and any subsequent
          nominations;

       f)      Unless sufficient pitches/plots can be provided from the above sources, existing
             pitches/plots with temporary planning permission will be considered; and

       g) Consider phasing of development sites particularly where supply exceeds need to
          protect future local needs options.

      24. The advice in the Sustainability Appraisal of these issues and options (page 156,
            Table 7.2 and supporting text) 4 was fairly limited given that there were mostly high –
            level options being discussed without much detail of relevant sites. The exception
            was option (c), referring to the extension of the Orchards at Chalfont St Peter. There
            were some negative factors associated with the extension to this existing site
            referred to in the Sustainability Appraisal report. However the site is referred to
            within Policy PW12 of the adopted Neighbourhood Plan for Chalfont St Peter5 for 6
            pitches and has the benefit of outstanding planning permission for the extension.
            Therefore the Sustainability Appraisal findings need to be read in that context and
            they do not prevent the option from further consideration as appropriate.

      25. The subsequent consultation on Green Belt Preferred Options for the Joint Local Plan
            in October – December 2016 set out the potential opportunities for meeting gypsy

4
 https://www.chiltern.gov.uk/media/7791/Sustainability-Appraisal-of-the-Chiltern-and-South-Bucks-
Local-Plan-Regulation-18-Inc-Issues-and-Options-Reasonable-Alternatives-Document-Lepus-January-
2016-/pdf/SA_Jan_16_options_with_Appendix_A.pdf?m=635888890289870000

5
 https://www.chiltern.gov.uk/media/6266/Chalfont-St-Peter-Neighbourhood-
Plan/pdf/Chalfont_St_Peter_Neighbourhood_Plan_(Final).pdf?m=636149789089830000

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         and traveller needs on the larger sites which were considered for removal from the
         Green Belt. These were as part of the Green Belt Preferred Options at Chesham
         (option 1), Little Chalfont (option 6), Beaconsfield (Option 8) and at land north of Iver
         Station (option 13).

     26. The Sustainability Appraisal for the Green Belt Preferred Options6 related to the 15
         options within that consultation. Four of these options were referred to in terms of
         having potential to meet the needs for new pitches (paragraph 5.3.3), as follows;

NE of Chesham – Option 1: Potential to accommodate a Gypsy / Traveller site
within the PO.
Under the SA10 indicator Housing this option scored +++.

Area South of Little Chalfont – Option 6: Potential to accommodate a Gypsy /
Traveller site within the PO.
Under the SA10 indicator Housing this option scored +++.

Area East of Beaconsfield – Option 9: Potential to accommodate a Gypsy /
Traveller site within the PO.
Under the SA10 indicator Housing this option scored +++.

Area North of Iver Station – Option 13: Potential to accommodate a Gypsy /
Traveller site within the PO.
Under the SA10 indicator Housing this option scored +++.

     27. The Chiltern and South Bucks Joint Committee report on 7.11.2018 provided an
         update on the green belt preferred options and all of the above sites were
         considered at that time as forming an appropriate mechanism to help meet the need
         for new accommodation for the gypsy and traveller community. [These options have
         been taken forward in the new Local Plan as site allocations at Chesham (Policy SP
         BP 2), Little Chalfont (Policy SP BP 6), Beaconsfield (Policy SP BP 9) and at land north
         of Iver Station (Policy SP BP 11).]

6
  https://www.chiltern.gov.uk/media/11505/Sustainability-Appraisal-for-Green-Belt-Preferred-
Options-Lepus-Consulting-September-2017-/pdf/LC-
330_SBucks__Chilterns_GB_SA_18_290917DS_compressed_Final_11_10_17.pdf?m=63643336101870000
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Methodology

Overview

     28. This document takes a similar approach to the Councils’ Housing and Economic Land
         Availability Assessment (HELAA). It adopts a structured and transparent approach
         showing how the opportunities for meeting the needs for gypsy and traveller
         accommodation were assessed including a search for accommodation opportunities,
         a high level assessment of constraints and opportunities, and a detailed assessment
         of specific sites for scope to provide new pitches.

     29. Additional information was taken into account given that the Topic Paper shows how
         the specific need for traveller pitches was addressed as distinct from new dwellings,
         for example taking into consideration the scope for intensification from existing sites
         already occupied by the gypsy and traveller community.

     30. This Topic Paper does not include information about the need for new plots for
         Travelling Showpeople as the GTAA need for this community is proposed to be met
         as part of the Green belt option at Holmer Green (now site allocation Policy SP BP3).
         The option includes an existing Travelling Showpeople site and advises that land for
         4 new plots will need to be delivered as part of the scheme.

Initial assessment

     31. A site analysis was undertaken of all sites that were known to the Councils from a
         variety of sources listed in (Table 2).

     32. The potential contribution of sites from within the settlements excluded from the
         Green Belt is limited by the generally high land values in these areas. As a result the
         sites in the Councils’ HELAA which are located in the settlements excluded from the
         Green Belt or on previously developed land in the Green Belt were not considered to
         be a relevant source of supply for consideration as part of the opportunities for new
         traveller pitches referred to in this Topic Paper. However in the event that a new
         pitch might come forward from these locations in future it is important that the Joint
         Local Plan includes a criteria-based policy for traveller pitches from windfall sources,
         e.g. potentially from unprotected employment sites in built-up areas provided that a
         satisfactory residential environment can be created or unforeseen opportunities on
         other previously developed land.

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Table 2 - Sources for testing potential sites for new traveller pitches

Source                  Description
Current       Permanent Sites occupied by the gypsy and traveller community which have
Sites                   lawful use or permanent planning permission

Current       Temporary Sites occupied by the gypsy and traveller community which have
Sites                   temporary planning permission

Current Expired Sites       Sites occupied by the gypsy and traveller community where
                            temporary permission had expired

Previous     refused Sites subject of proposed new pitches for the gypsy and traveller
planning applications community where permission had been refused7
or pending planning
applications

Allocations        in This related to the Approved Chalfont St Peter Neighbourhood
Neighbourhood Plans   Plan

Call for Sites (2016 – Initial inclusion of any sites which were suggested as part of the
2017)                  call for sites on the regulation 18 consultation on the Joint Local
                       Plan, the previous regulation 18 consultation for the Chiltern Local
                       Plan (2016) and the South Bucks Traveller Topic paper (2015)

Provision on    land This was not considered a deliverable option given that the
owned by the District Districts do not own extensive areas of land (Bucks CC sold its five
Councils              public gypsy and traveller sites in Chiltern and South Bucks in
                      2016).

Green Belt Preferred Potential new pitches as part of site allocations in the new Local
options     /    site Plan. This is set out separately in this Topic paper
allocations

Duty to Co-operate          There were no opportunities to accommodate needs from
                            neighbouring Bucks Councils as set out in the agreed
                            Memorandum of Understanding between the Councils.

                            No opportunities have arisen as a result of discussions with other
                            neighbouring authorities as part of the duty to co-operate.

Park Homes                  Existing park homes sites in the plan area were not considered as
                            they do not fulfil the cultural needs for the traveller community,

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  Sites which had been the subject of enforcement action to remove unauthorised pitches were not
included as part of the testing process – these were at Tobys Stables, Alderbourne Cottage, Bramley
Apple Farm, Asheridge and at Lodge Lane, Little Chalfont.
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Source                      Description
                            with the need for families to live as a group, allowing shared caring
                            for family members. There are also issues in terms of the design
                            and layout of park homes sites – the need for larger pitches to
                            include touring caravans, sufficient open space and amenity blocks
                            for each pitch.

                            The work also including checking of website advertised vacancies
                            for the existing park home sites in the Local Plan area for a sample
                            period between the end of December 2016 and October 2018 and
                            no vacancies were found.

Rural exceptions            The key issue for rural exceptions policy is affordability and the
                            GTAA does not include information on whether the occupiers of
                            existing sites are specifically in need of affordable pitches and
                            whether mechanisms exist to ensure that sites remain affordable in
                            the long term. It would remain open to the Councils to determine
                            applications within the Green Belt on the basis of their merits
                            including any very special circumstances in any case. Therefore the
                            potential from rural exceptions was not considered as a source of
                            supply for the purposes of this Topic Paper.

Call for sites for This also included an invitation to submit sites which could be
updating the HELAA in appropriate for the travelling community8
Dec 2018 – Feb 2019

     33. An initial list of sites to consider was compiled after reviewing all of the sources
         listed above. This is as set out in Table 3 and includes 30 sites.

     34. The purpose of this stage was to devise a long list of potential sites for consideration
         and then identify whether there were high-level constraints / other factors which
         would indicate that they were either suitable or not suitable for further assessment.

Table 3: Sites that were assessed at the Initial assessment stage

Site Location                        Source                            Reason for inclusion /
                                                                       removal from further
                                                                       consideration

51 Thorney Mill Road, Iver           Existing Site                     Existing site - relevant to
                                                                       assess further for

8
 http://www.chiltern.gov.uk/callforsites and
http://www.southbucks.gov.uk/callforsites

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Site Location                        Source                           Reason for inclusion /
                                                                      removal from further
                                                                      consideration

                                                                      intensification
                                                                      opportunities

Land north of Bakers Wood,           Refused Planning Permission      Not pursued based on
Denham                                                                the refusal of planning
                                                                      permission – adverse
                                                                      impact on the Green Belt,
                                                                      Colne Valley Park and
                                                                      impact on the
                                                                      Biodiversity Opportunity
                                                                      Area

Bottoms Walton, Walton Lane,         Existing Site                    Existing site - relevant to
Burnham                                                               assess further for
                                                                      intensification
                                                                      opportunities

Bramley Apple Paddocks,              Refused Planning Permission9     Not pursued based on
opposite Tiles Farm, Asheridge                                        the refusal of planning
                                                                      permission – adverse
                                                                      impact on the Green Belt,
                                                                      AONB, setting of Listed
                                                                      Buildings and Highway
                                                                      Safety. Occupants have
                                                                      left the site (as at Feb
                                                                      2019)

Dudley Lodge, Mansion Lane,          Existing Site                    Existing site - relevant to
Iver                                                                  assess further for
                                                                      intensification
                                                                      opportunities

Dudley Wharf, Mansion Lane,          Existing Site                    Existing site - relevant to
Iver                                                                  assess further for
                                                                      intensification
                                                                      opportunities

Garry Owen (Wenman Site),            Existing Site                    Existing site - relevant to
Love Lane, Iver                                                       assess further for
                                                                      intensification
                                                                      opportunities

9
    Subsequently dismissed on appeal and enforcement action upheld.
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Site Location                  Source                           Reason for inclusion /
                                                                removal from further
                                                                consideration

Gooseberry Hill, Iver Heath    Pending Planning Application     Pending retrospective
                                                                application as at 6 11
                                                                2018 17/00757/FUL.
Green Acres Farm, West Hyde    Existing Site                    Existing site - relevant to
Lane, Chalfont St Peter                                         assess further for
                                                                intensification
                                                                opportunities

Green Park, Copperkins Lane,   Existing Site                    Existing site - relevant to
Amersham                                                        assess further for
                                                                intensification
                                                                opportunities

Land Adjacent to Former        SBDC Call for Sites 2014         Not an existing site,
Hedgerley Reservoir,                                            located on undeveloped
Hedgerley                                                       land in the Green Belt.
                                                                Not appropriate to assess
                                                                further
Land Adjacent to Jewsons,      Chiltern Delivery DPD Call for   Site not considered
Chesham Road, Hyde End         Sites 2013                       reasonably available for
                                                                new pitches –
                                                                applications in 2017 for
                                                                associated use related to
                                                                adjoining builders yard.
Land South of Mansion Lane     Existing Site                    Existing site - relevant to
Caravan site, Mansion Lane,                                     assess further for
Iver                                                            intensification
                                                                opportunities

Little Sutton Lane, Langley    Existing Site                    Existing site - relevant to
                                                                assess further for
                                                                intensification
                                                                opportunities

Mansion Lane Caravan site,     Existing Site                    Existing site - relevant to
Iver                                                            assess further for
                                                                intensification
                                                                opportunities

Misbourne Farm, Chalfont St    Chiltern Delivery DPD Call for   Not appropriate to
Giles                          Sites 2013                       consider further as this
                                                                land was proposed as a
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Site Location                   Source                             Reason for inclusion /
                                                                   removal from further
                                                                   consideration

                                                                   site for Travelling
                                                                   Showpeople and the
                                                                   specific need for the
                                                                   accommodation for the
                                                                   Misbourne Group was
                                                                   not upheld by the latest
                                                                   GTAA

                                                                   Also the site is partly
                                                                   located within the River
                                                                   Misbourne Flood Zones
                                                                   and would fail the NPPF
                                                                   sequential test

Ponderosa, Love Lane, Iver      Existing Site                      Existing site - relevant to
                                                                   assess further for
                                                                   intensification
                                                                   opportunities

White Hill, off the A355        Former public transit site         No longer used to
Beaconsfield                                                       accommodate travellers
                                                                   so not considered as a
                                                                   current site or to be
                                                                   reasonably available for
                                                                   the travelling community
Pyebush Lane, Beaconsfield      SBDC Call for Sites 2014           Not an existing site,
                                                                   located on undeveloped
                                                                   land in the Green Belt.
                                                                   Not appropriate to assess
                                                                   further
Renard, Hollybush Lane,         Existing Site                      Existing site - relevant to
Shredding Green, Iver                                              assess further for
                                                                   intensification
                                                                   opportunities

The Orchards, West Hyde Lane,   Existing Site                      See also section relating
Chalfont St Peter                                                  to the Chalfont St Peter
                                                                   Neighbourhood Plan.
                                                                   This is an existing site.

The former Pheasant PH, Raans   Chiltern DPD Call for Sites 2013   Not proposed by the
Road, Amersham                                                     travelling community,
                                                                   now developed for
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Site Location                     Source                         Reason for inclusion /
                                                                 removal from further
                                                                 consideration

                                                                 housing and site includes
                                                                 listed building – not
                                                                 appropriate to assess
                                                                 further

The Vale, Chesham                 Existing plot for Travelling   Not appropriate to assess
                                  Showpeople                     for gypsy and traveller
                                                                 community – excluded
                                                                 from further assessment
The Warren, Rowley Lane,          Existing Site                  Existing site - relevant to
Wexham                                                           assess further for
                                                                 intensification
                                                                 opportunities

Thorney Stables, Thorney Lane     Existing Site                  Taken forward as part of
North, Iver                                                      a site allocation in the
                                                                 Green Belt for the Local
                                                                 Plan – occupants due to
                                                                 move to bricks and
                                                                 mortar.
Three Oaks Farm, Roberts          Existing Site                  Existing site - relevant to
Lane, Chalfont St Peter                                          assess further for
                                                                 intensification
                                                                 opportunities

Waggoners Bit, Whielden Lane,     Existing Site                  Existing site - relevant to
Amersham                                                         assess further for
                                                                 intensification
                                                                 opportunities

Wapseys Wood, Oxford Road,        Existing Site                  Although this is an
Gerrards Cross                                                   existing site it is subject
                                                                 of complex enforcement
                                                                 action – excluded from
                                                                 further assessment

Wickford Farm, Pinstone Way,      Existing Site                  Existing site - relevant to
Tatling End                                                      assess further for
                                                                 intensification
                                                                 opportunities

Willow Tree Farm (Porter Site),   Existing Site                  Existing site - relevant to
Swallow Street, Iver                                             assess further for
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Site Location                       Source                             Reason for inclusion /
                                                                       removal from further
                                                                       consideration

                                                                       intensification
                                                                       opportunities

Testing of constraints

     35. As a result of this screening process not all of the 30 sites emerging from the
         different site sources were considered suitable to be taken forward for further
         assessment. 10 sites were, in effect, eliminated and 20 were taken forward to the
         next stage. The details of the constraints which were used are set out in Table 4. The
         work included visits to view potential sites from public vantage points, considering
         relevant planning applications, landownership information from the land registry and
         digital image mapping.

     36. The constraints testing work had close parallels with sustainability principles. The
         objective was to give an overall assessment of the positive and negative
         characteristics of the sites to feed into further work. Also the work took into account
         sites which were close to the boundary of the Local Plan area in relation to nearby
         facilities, e.g. if a local shop was beyond the Chiltern or South Bucks boundary was
         still classed as the closest shop to a traveller site for the purposes of the assessment.
         This also applied to primary schools and GPs etc. If a proximity factor was beyond
         the Local Plan area boundary the distance was measured by Google Maps only as
         GIS maps are not available outside of the Local Plan area. Testing the potential for
         pitch provision as part of site allocations in the Local Plan was not part of this
         process as it was comprehensively covered in the overall assessment of constraints
         and opportunities for site allocations. This is explained more in Appendix 2.

Table 4: Detailed Site Analysis criteria

Site analysis criterion                           Criteria Used to compile the site analysis
                                                  spreadsheet

Air Quality Management Area (AQMA)                If site was within the GIS Layer for the AQMA

An Archaeological Priority                        If site was within the GIS Layer for the Area /
Area/Archaeological Notification Site             Site

Ancient Monument                                  If site was within the GIS Layer for the site
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Site analysis criterion                           Criteria Used to compile the site analysis
                                                  spreadsheet

(Scheduled Monument)

Ancient Woodland                                  If site was within the GIS Layer for the
                                                  woodland

Biodiversity                                      If site was within the GIS Layer

(Including Sites of Special Scientific Interest
(SSSIs), Regionally Important Geological /
Geomorphological Sites (RIGs), Local Nature
Reserves (LNRs), Local Wildlife Sites and
Special Areas of Conservation (SACs))

Chilterns AONB                                    If site was within the GIS Layer for the AONB

Colne Valley Park                                 If site was within the GIS Layer for the Park

Conservation Area                                 If site was within the GIS Layer for a
                                                  Conservation Area
Flood Zone                                        A traffic light system was employed for
                                                  testing surface water flood risk and the site
(Environment Agency maps showing the Risk         analysis was on the basis of the highest level
of Surface Water Flooding (RoSWF))                of risk for the site (for example, if half the site
                                                  was in a Red Zone and the other half was in a
Flood Zone (Environment Agency maps               Green Zone the cell would be coloured Red),
showing fluvial flooding)                         this was to ensure that the flood risk was
                                                  fully considered to give a precautionary
Flood Zone (Groundwater Flooding data             approach even though this might have been
from Jeremy Benn Associates)                      a small part of the site. These matters could
                                                  be addressed as part of Flood Risk
                                                  Assessments for the sites if taken forward.

                                                  The RAG analysis used for the flood risk
                                                  testing was as follows

                                                  Red - flood zones within the site boundary
                                                  were marked as red and a description was
                                                  added to the analysis to explain where in the
                                                  site the flood zone was located together with
                                                  any other nearby areas affected by flood risk
                                                  also described.

                                                  Amber – flood zones that were along the
                                                  boundary to the site but not inside, and
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Site analysis criterion                          Criteria Used to compile the site analysis
                                                 spreadsheet

                                                 nearby large flood zones were also
                                                 described.

                                                 Green – flood zones were not within the site
                                                 or along the boundary, description of flood
                                                 risk zones further away from the site were
                                                 added.

GP Surgeries                                     Distance in miles to the nearest GP practice

Green Belt                                       If site was within the GIS Layer for the Green
                                                 Belt
Green Spaces and Public Open Spaces              If site was within the GIS Layer for public
                                                 opens spaces identified in the Adopted Local
                                                 Plans for both Districts

Historic Park and Gardens                        If site was within the GIS Layer for these
                                                 designations

HS2 Safeguarding Line                            If site was within the GIS Layer for the
                                                 safeguarding line

Listed Buildings                                 If site was within the GIS Layer for Listed
                                                 Buildings

                                                 Whether a site might affect the setting of a
                                                 nearby Listed Building would be a matter for
                                                 the detailed assessment of sites.
The sites were tested in relation to proximity
to local/district Shopping Centres,
convenience shops, GP surgeries and primary
schools as explained in Appendix 2

Public Transport (Distance to Bus Stops) and
Public Transport (Distance to Train Stations)
was also measured using the methodology
set out in Appendix 2

Site Access                                      This was noted in terms of whether a site had
                                                 an existing access to a public road

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     37. The results of this testing process are set out in Appendix 3.                   Much of the
         information on constraints was coded using a Red – Amber - Green (RAG) system.
         This was to give an overview of the performance of the sites against the criteria, for
         example the terminology was:

                  Red – a site includes or falls within a specific constraint
                  Amber – a site adjoins or is reasonably close to a specific constraint
                  Green – a site does not include or fall within a specific constraint

     38. No weighting was applied in relation to assessing the constraints, and it is noted that
         some constraints could be mitigated or overcome through planning conditions, e.g.
         to mitigate noise, to improve screening, to provide SUDs, etc. This work was needed
         to provide a context for considering the opportunities for intensifying or expanding
         the number of pitches on existing sites and the results of this testing process were
         taken into account in the review of intensification opportunities for existing gypsy
         and traveller sites as set out below.

Intensification opportunities from existing traveller sites within the Green Belt

     39. There were eight sites which were considered to be appropriate for further testing
         for potential intensification opportunities for the provision of new pitches.

     40. All of the existing gypsy and traveller sites in the plan area are located in the Green
         Belt. They do not adjoin the edges of existing settlements which are excluded from
         the green belt. They tend to be in locations which are at a distance from nearby
         settled communities, often forming small family – based groupings of pitches. These
         locations would not form logical extensions to nearby settlements but are more akin
         to free-standing communities.         The protection of the Green Belt is a long term
         objective of the Councils and is at the heart of the new Local Plan 2036 strategic
         vision.

     41. National policy relating to Green Belt reviews is that exceptional circumstances need
         to be demonstrated to underpin the review of their boundaries. The first part of this
         process is the assessment of whether the need for gypsy and traveller pitches can be
         met outside of the Green Belt or on previously developed land in the green belt. The
         process described above shows how potential opportunities for new pitches were
         assessed. Locations outside the Districts’ green belt are unlikely to come forward
         given the high local land values in the towns and villages in the Local Plan area and
         the likely proximity to sensitive land uses. As a result existing traveller sites were
         considered appropriate for more detailed consideration, notwithstanding their
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         location within the green belt. Therefore it was important that the work in assessing
         potential opportunities for new traveller pitches sought to minimise adverse impacts
         on the Green Belt whilst catering for the needs for new pitches, preferably in
         locations reasonably related to where the need for new pitches was likely to arise.
         Therefore, testing infilling opportunities on existing sites was considered an
         appropriate way to carry this out, together with analysing the potential related to
         outstanding planning applications from the sites already inhabited by the travelling
         community.

     42. Part of this work included a review of relevant planning applications to aid
         understanding of site constraints and opportunities. The sites which were included in
         the infilling assessment are included in Appendix 4. Assessment of outstanding
         planning permissions was a key part of this. The Appendix lists the sites where there
         is scope for outstanding / pending planning applications could be permitted to
         provide a supply of new pitches. Further information on the reasoning for this is
         included within the relevant site proformas relating to the assessment of infilling
         opportunities (Appendix 5).

     43. In summary, the outcome of the assessment of infilling opportunities was that there
         was quite a lot of scope to address needs via the determination of current
         applications subject to very special circumstances being demonstrated. Some of the
         planning applications have been outstanding for a number of years. Other existing
         sites are already fairly closely developed with their existing pitches leaving limited
         room for intensification within their current boundaries. This is not unexpected given
         the high level of constraints on potential supply within the Local Plan area and
         limited opportunities for meeting needs over a long period. As part of this process
         the importance of taking a realistic approach to space standards for the sites was
         highlighted so as not to create overcrowding.

     44. Alongside the provision of new pitches from Local Plan site allocations, (15 per
         allocation for four allocations), the role of outstanding planning permission could
         have a substantial effect on meeting needs.

The Chalfont St Peter Neighbourhood Plan

     45. The Chalfont St Peter Neighbourhood Plan states in Policy PWI2 that “if additional
         plots for travellers are needed, the further development of around six pitches at the
         existing approved site, The Orchards, will be supported”. Therefore, the findings in
         Appendix 5 of this Topic Paper refer to the potential for new pitches as a result of
         this neighbourhood plan policy, in terms of an additional six plots to assist in
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         meeting Gypsy and Traveller needs. However it is also appropriate to test whether a
         higher level of pitches could be accommodated within the same site extent as that
         already permitted. This has also been tested, as explained in the relevant site
         proforma in Appendix 5.

Pitch provision as part of site allocations in the new Local Plan

     46. Integrating Gypsy and Traveller provision within large scale strategic allocations is
         becoming an increasing trend given the need to consider a range of opportunities
         which may be appropriate for accommodating needs in Local Plans. For Chiltern and
         South Bucks, provision of new traveller pitches is a strategic issue since all existing
         gypsy and traveller sites in the Local Plan area are located within the Green Belt.

     47. It is important that the Local Plan’s provision for travellers is consistent with the
         strategy for meeting the needs of the settled community. For the settled community
         the Local Plan is providing opportunities through the site allocations in sustainable
         locations where they exist, given that the Local Plan area is heavily constrained. It is
         important to provide a similar approach for the traveller community, creating
         opportunities for new pitches which have good access to facilities, as highlighted in
         the advice in PPTS in terms of providing new pitches in sustainable locations (PPTS
         paragraph 13 for example). Therefore, with limited supply, sustainable locations and
         national policy all point to the main site allocations. In addition, these sites are not
         at great distances from existing Traveller communities. The site allocations in the
         Local Plan are well located to the strategic highway network and have good access
         to local services and facilities. The four larger site allocations in the Local Plan which
         have been identified for new pitches are at Chesham (Policy SP BP 2), Little Chalfont
         (Policy SP BP 6), Beaconsfield (Policy SP BP 9) and at land north of Iver Station (Policy
         SP BP 11).]

     48. Aylesbury Vale District Council and Dacorum Borough Council have both proposed
         new pitches as part of strategic site allocations to assist in meeting their Gypsy and
         Traveller needs.

     49. Aylesbury Vale has two site allocations, D-AGT1 and AGT2, which include 5 pitches
         on each site with between 1,000 and 1,550 dwellings in their Local Plan which is the
         subject of a current Examination.

     50. Dacorum BC has two urban extensions including some Gypsy and Traveller provision.
         This is within Policy LA1 for 5 pitches as part of a 300 - 350 dwellings site and LA3

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         for 7 pitches as part of a 900 dwellings site. This Local Plan has been adopted by the
         Council and therefore this approach was accepted by their Inspector.

     51. Milton Keynes Council allocated traveller pitches within a strategic allocation for
         3,000 dwellings. This was agreed by the Local Plan Inspector and is now included
         within the adopted Milton Keynes Local Plan.

     52. Therefore, Chiltern and South Bucks District Councils will be following a similar
         approach to the above examples within selected sites allocations which are
         proposed to be removed from the Green Belt (Table 5).

        Table 5 – Local Plan sites being required to deliver new pitches

Site allocation number      Site                                 Number of Pitches needed
(Former       Green    Belt
Preferred Option number)
Policy SP BP 2 (01)         North of Chesham                                  15

Policy SP BP 6 (06)                Little Chalfont                            15

Policy SP BP 9 (09)                East of Beaconsfield                       15

Policy SP BP 11 (13)               Land north        of   Iver                15
                                   Station

                           Total                                                 45

    53. The agent / landowner contacts for these sites have all been made aware of the need
        to seek opportunities for new pitches as part of the overall scheme for the sites. The
        provision of new pitches for these sites was flagged up some time ago in 2016 as part
        of the Local Plan consultation on Green Belt Preferred Options. None of the agents /
        owners has submitted information to evidence why this type of need could not be
        accommodated as part of their scheme.

    54. The mechanisms for providing pitches on site allocations are not specified in detail in
        this paper or in the new Local Plan. However access and utility service will need to be
        provided. The Councils are intending to ensure that the developers of the sites take
        an enabling approach to the provision of new pitches. Matters such as the tenure of
        the pitches, costs of provision, access and site design will need to be subject to
        discussions as part of the master planning process for specific sites.

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Findings

     55. Taking into account the process for finding sites for new pitches the table below
         shows how they could be delivered.

Table 6 – summary of the estimated supply of new pitches

Supply sources                          No of pitches                 Commentary       on         likely
                                                                      delivery timeframe

Estimated supply from the Chalfont      6 pitches - but potential
St Peter Neighbourhood Plan             contributions      recorded
                                        under category below to
                                        avoid double counting
Estimated supply from existing gypsy    34 - 39 pitches               Likely to be within the first five
and traveller sites via the planning                                  years     via     the   planning
application process and subject to      Of this 21 – 26 in Chiltern   application process and subject
very special circumstances              District and 13 pitches in    to very special circumstances
                                        South Bucks District

New      pitches     from    planning   1 pitch                       Pitch      already     provided
applications – Land at Little Sutton                                  (previously    has   temporary
Lane, Iver - permitted March 2019.                                    planning permission)

Estimated supply from move to           2 pitches       no   longer   Dependent on phasing of the
bricks and mortar accommodation         required                      site subject of Local Plan Policy
(Thorney Stables, Iver)                                               SP BP 12, not likely to be within
                                                                      the first five years

Scope for new pitches to be assessed    Not known                     Pitches would be after adoption
under the criteria – based DM policy                                  of the plan
for Gypsies and Travellers

Provision which could be met outside    0
the Local Plan area via the Duty to
Co-operate
Provision from the four sites           45                            Dependent on phasing of site
(Chesham, Little Chalfont, land north                                 allocations, unlikely to provide
of Iver station and Beaconsfield)       (Estimated that 15 pitches    new pitches within first five
                                        could be provided on each     years
                                        site)
Balance over whole plan period          81 – 87 compared to a
                                        total need of 85 pitches

Balance over the first five years to    35 – 40 compared to a
2021                                    five year need of 45
                                        pitches

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     56. As acknowledged previously, this work is taking into account cultural need for new
         pitches and shows that overall needs can be met within the Local Plan period.
         However there would be a slight shortfall against five year needs, taking into account
         overall cultural need.

     57. One of the existing sites in Iver has now been the subject of a permanent permission
         for one pitch. Therefore this effectively reduces the outstanding number of pitches
         to meet all needs by one to 84 pitches (and to 44 for the first five years).

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Conclusions

     58. The GTAA results for Chiltern and South Bucks show the composition of needs at the
         time of the relevant survey. The needs for the Local Plan area as a whole were shown
         to be a high level of non-travelling households and households whose travelling
         habits were unknown. This can be subject to change as travelling habits will vary
         according to the personal circumstances of individual households. As a result it is
         appropriate for the Councils to have a strategy for gypsy and traveller
         accommodation which seeks to meet wider cultural need.

     59. The findings of this Topic paper show that there is a supply of pitches equivalent to
         the total number of pitches needed for all types of need (85 pitches). This supply has
         been assessed by taking into account a range of potential sources of supply, in
         particular existing gypsy and traveller sites and the opportunities provided by new
         site allocations in the Local Plan. Of this supply, a very significant contribution
         towards short term needs arises primarily from outstanding planning applications on
         a number of existing sites. The outcomes of these planning applications will be
         closely monitored alongside the overall needs, as will the progress on site delivery
         from the site allocations.

     60. In terms of the timescale for the delivery of new pitches, the outstanding planning
         permissions in some cases relate to pitches already in existence. Therefore granting
         permanent permissions will help to address shorter-term five year needs. It is
         estimated that 35-40 pitches will be provided / are likely to be provided within the
         first five years of the Plan period. This would represent a significant contribution
         towards meeting the level of overall needs for the first five years based on all types
         of need shown in the GTAA (45 pitches).

     61. Delivery as part of site allocations is expected to take longer. The four sites which
         have been identified as providing new pitches are not currently expected to start
         delivering until later in the Plan period and pitches on these sites would help to
         address longer term needs.

     62. There are other issues relevant to the consideration of the supply of new pitches in
         the context of a Local Plan with a time horizon to 2036. These include cultural issues,
         the need for good amenity standards and the planning conditions which it could be
         appropriate to impose. New pitches provided will need to be sensitive to the cultural
         context. In particular, the provision of park homes is not likely to meet cultural need
         since these would not be likely to include amenity blocks or space for touring
         caravans to undertake travelling. In terms of amenity and design there are no

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         specific standards for floorspace per pitch. This is because family needs will vary.
         However there are fire and licensing standards relating to the spacing between
         caravans. Also 1 pitch per 500 sqm is generally accepted as good practice. Appendix
         6 includes a range of potential planning conditions which can be used to control or
         mitigate the impact of such sites, such as landscaping conditions, height of
         development, etc. Occupancy will need to be closely controlled to ensure that the
         new pitches will be provided to meet the needs of gypsies and travellers, not other
         groups.

     63. The new Local Plan has a criteria-based policy (DM LP 9) which would apply to any
         planning applications for new pitches / sites for gypsies and travellers.

     64. The Councils will monitor the delivery of new pitches from the planning application
         process and those delivered as part of the site allocations and the Chalfont St Peter
         Neighbourhood Plan. Progress will be reported in future monitoring reports
         (Authorities Monitoring Reports).

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References

Chalfont St Peter Parish Council (2016) Chalfont St Peter Neighbourhood Plan
https://www.chiltern.gov.uk/media/6266/Chalfont-St-Peter-Neighbourhood-
Plan/pdf/Chalfont_St_Peter_Neighbourhood_Plan_(Final).pdf?m=636149789089830000

Chiltern and South Bucks District Councils (2016) Regulation 18 consultation on Issues and
Options for the Joint Local Plan https://www.chiltern.gov.uk/media/7771/Chiltern-and-
South-Bucks-Local-Plan-Regulation-18-Incorporating-Issues-and-Options-Consultation-
Document-Jan-Mar-2016-
/pdf/FINAL_Reg_18__Issues_and_Options_Consultation_Paper.pdf?m=635883791899170000

Chiltern and South Bucks District Councils (2016) Green Belt Preferred Options consultation
on the Joint Local Plan https://www.chiltern.gov.uk/media/8628/Green-Belt-Preferred-
Options-Consultation-Document-Oct-Dec-2016-
/pdf/Preferred_Options_Consultation_Document_-_Final.pdf?m=636130734232770000

Chiltern and South Bucks District Councils (2017) draft Housing and Economic Land
Availability Assessment (HELAA) https://www.chiltern.gov.uk/media/9629/Draft-Housing-
and-Economic-Land-Availability-Assessment-HELAA-May-2017-
/pdf/CDC_and_SBDC_HELAA_Update_(May_2017).pdf?m=636319102893600000

Buckinghamshire Memorandum of Understanding between Aylesbury Vale District Council,
Wycombe District Council, Chiltern District Council, South Bucks District Council, and
Buckinghamshire            Thames   Valley    Local   Enterprise    Partnership       (2017)
https://www.chiltern.gov.uk/media/10814/Buckinghamshire-Memorandum-of-
Understanding-AVDC-WDC-SBDC-CDC-and-Bucks-Thames-Valley-LEP-July-2017-
/pdf/Bucks_Districts___LEP_MOU_FINAL_18.7.17.pdf?m=636360535921500000

MHCLG (2019) National Planning Policy Framework and on – line Planning Practice Guidance

DCLG (2015) Planning Policy for Traveller Sites

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